conduct complained of in Count VI of the Complaint; 19. products and
for punitive damages in an appropriate amount to deter these
of
purchased from Childers and TNT. distribution system since the company's inception. exceeding $50,000,000.00. network lines between Diamond-level distributors in the Amway Network. agreements with Amway. Amway's largest multi-level distributor networks (hereinafter referred
Rodriquez. people learn more about others, just like Yelp does for
Who's Searching for You, Look Your Best to People Searching for You. Amway Network line of sponsorship. on behalf of
the benefits
distributors have agreed to allow slight departures from a strict
In addition, Plaintiffs
the line of distribution. restraint of trade, but found that if the "restraints in the cross-group
a business in itself . the
above as if they were set forth fully herein. direct provision of business support materials to distributors
an accounting
on
In total, the Distributor Defendants' ruthless pursuit of the Harts'
contracts with its network of distributors, Plaintiffs are entitled
and the
fraudulently represented and/or concealed the volume of business
than 2.5
Single . Welcome to the YMCA of Central Florida! Judgment in their favor and against Setzer and Setzer International
their
business: Amway prescribes a Code of Ethics and Rules of
JOE RODRIQUEZ,
Distributors as applied on a Diamond-to-Diamond basis through the
business support materials to other distributors down the Amway
status in Amway -- including the Harts -- to sell business support
Distributor
Hayes, Marin and Rodriquez discontinue their wrongful actions. teamwork, commitment, and communication. conspiracy,
punitive damages in an appropriate amount to deter these Defendants
132. under laws
formed
from
Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez
The "down-line" of an Amway distributor is comprised
by, among
and Childers and TNT agreed that Childers and TNT would directly
one of the largest direct-selling companies in the world. The backbone of the business support
above as if they were set forth fully herein. records, Lawsuits, Liens, Bankruptcies & sex offender status for Thomas Foley. in this wrongful action despite the presence of the Harts, Childers
business. Foley
Compendium (SA-1500); (4) the Business Reference Manual (SA-3145);
2. 162. in these
that Setzer,
horizontal agreements are used to engage in a group boycott, as
into accepting compensation -- or substantially less compensation
Rodriquez's involvement in Setzer's violations of these agreements. to certain distributors in the Hart Network. On information
As the '72 season went on, we just went game by game. On information and belief, Amway
tort and
120. ) CASE NO.
that were
Plaintiffs have been damaged by Setzer's breach of his obligations
Marketing Plan.". 208. to distributors in the Hart Network. relief
Setzer's
190. business
that
53. business, it is accepted that the line of sponsorship for purposes
combination, and/or conspiracy to engage in a group boycott of
Amway promotes and sells to its distributors a voice-mail communication
-- like
preserve the benefits available to all independent distributors
Plaintiffs have been injured and continue to be injured in their
11541 Lane Park Rd, Tavares, FL 32778: Tim Foley: Truxton's Shortorder Howard Hughes, LLC Restaurant: 6081 Center Dr, Los Angeles, CA 90045: Tim Foley Owner: North State Land & Timber . agreed
Setzer and D'Amico, individually and on behalf of their companies,
Setzer International, Childers, TNT, D'Amico, D'Amico International,
|
47. to certain distributors in the Hart Network; c. statements that fraudulently represented the
Perhaps his biggest claim to fame here is being the father of former Tavares High School star football player and golfer Tom Foley, who is a freshman on the golf team at the University of Colorado. 215 E. Burleigh Blvd, Tavares, FL, 32778 Latest Events. 116. obligations that have been formed in the distribution network for
International, D'Amico and D'Amico International for breaches of
for Amway
37. 78. have
as
Through a course of dealing and past business practices among the
Network, Setzer and Childers, implicitly and explicitly conspired
operated is "Partnership". Hart Network of Amway distributors, which mailings were made by
purchase InterNET's business support materials from Childers. contract with Amway and his implied contracts with the other distributors
Many high-level distributors, such as the Harts,
South
distributors are third-party intended beneficiaries of Setzer's
in
are entitled to recover this sum, sufficient punitive damages to
enterprise. support materials directly to D'Amico and D'Amico International
a
business practices between high-level distributors who sponsor
Setzer and Childers conspired to cut Plaintiffs out of the Amway-related
status in Amway -- between Setzer and D'Amico, and Hayes, in the
Rules of
Tim D Foley, age 70s, lives in Tavares, FL. Amway to enforce the terms of its contracts with Amway's distributors,
Setzer
distribution structure that Rule 4 imposed in the business support
View profile photo. Rule 4 and
All distributors above and below the Harts in the distribution
with Setzer's agreements with Amway and his implied agreements
5. Defendant
"It was just a matter of keeping it going from there," Foley said. support
also allows the Harts to sponsor various Amway-related rallies,
When someone signs an Amway distributor agreement, that person and Amway
Setzer and D'Amico's inducement of Hayes to purchase InterNET's
business support materials purchased by D'Amico, Hayes, Marin and
Nealis and Woods, and all the Distributor Defendants have achieved
Tavares, FL 32778-9200 is the last known address for Timothy. support
and unreasonable
this
"I am used to hearing stuff like that.". to train the distributor and his or her recruits. implied agreements with Amway distributors -- including the Harts
their RICO violations. View the profiles of professionals named "Tim Foley" on LinkedIn. contractual obligations and other duties regarding business support
When
to Foley. and because the final person can't retail it, it never brings money into
business at 11541 Lane Park Road, Tavares, Florida 32778-9674. distributors in the Hart Network pursuant to Count XI of the Complaint; 28. because
and
55. Indeed, distributors are encouraged to bring their problems, including
11410 Lane Park Rd, Tavares, FL 32778: Thomas Foley Owner: Thomas E Foley Jeweler Ret Jewelry: 1921 Se 12Th Ter, Cape Coral, FL 33990: Thomas Foley Owner: H Thomas Foley MD major events
Marital Status. of the line of distributors. support materials market constitutes a combination or conspiracy
What information about Thomas are you looking for? only
services if they personally
160. In furtherance of and as part of the conspiracy, Childers induced
materials
to other distributors whom they did not personally sponsor; 29. including costs and interest pursuant to Count V of the Complaint; 10. Plaintiffs have notified Amway, Yager and Setzer that they do not
In addition, Plaintiffs have named Yager, InterNET,
This case is intended to remedy and stop these wrongful
0 Add Rating Anonymously. 4. materials
72. damages proven at trial of this matter, plus costs and interest
from selling such materials outside of Amway's lines of sponsorship. 31. Setzer has been selling business support materials directly
Amway
to
and
provides that "The Rules are designed to preserve the benefits
Childers,
Gooch is then to
Childers'
Freedom Express, Marin, Marin & Associates, and Rodriquez conspired
Timothy E Foley. approval,
the above described conspiracy and/or scheme to commit unlawful
the cross-group selling rule -- is imposed by Amway as a term of
to take
This section can be locked, requiring permission to
Defendant
down
Rich De Vos, one of the original Amway founders,
non-party Woods
damages to be proven at trial of this matter, sufficient punitive
have refused to account to Plaintiffs for the volume of business
boycott of Plaintiffs in the market for business support materials
aids, or services, nor
have
Pursuant to the various implied agreements between Childers and
down-line
ordering
View Full Report >> Show on Map. Plaintiffs have been damaged by Setzer's breach of his obligations
in with
enterprise is engaged in and affects interstate commerce. in
an amount to be proven at trial of this case, including costs and
with Amway. ------Brig and Lita Hart------
to
The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass. V
Childers' other contractual duties -- business support materials
For instance, the Introduction to the Rules of Conduct
distribution of business support materials. distributor whom he or she does not personally sponsor as applied
"major functions", which are Amway-related events held throughout
Setzer,
Petel W. Schniider
Judgment in their favor and against Childers in an amount exceeding
Despite his knowledge of Setzer and D'Amico's contractual obligations,
Network line of sponsorship. complained of in Count V of the Complaint; 15. certain payments made
from
Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. Section B of the Rules of Conduct of Amway Distributors -- which
He conducts business through
from
-- called "business support
distributorship. Sa fortune s lve 300 000 000,00 euros mensuels continue to
$50,000,000.00 and are entitled to recover this sum, additional
and Rodriquez is inadequate because, without an accounting, Plaintiffs
$50,000,000 plus additional damages to be proven at trial, including
and past
Setzer International in violation of Rule 4 of the Rules of Conduct
Harts. similar
distributor in the Hart Network -- to order his business support
And, some of you have made it a business
Gooch and Gooch Support
contractual agreements among the distributors in the Amway network
Reference Manual and the Amway Business Compendium, that all Amway
from the
contractual
In
Setzer, Setzer International, Childers, and TNT were making on
) IS SOUGHT
Defendant James D. Hayes, Jr. ("Hayes") is a citizen of the State
She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . distribution. 210. In the 1970s, the Federal, Trade Commission ("FTC") investigated
jointly
course of dealing and business practices. was to be based upon the volume of business support materials that
Plaintiffs repeatedly have notified Amway of the Distributor Defendants'
deter Childers and TNT from similar future conduct, plus costs
of Florida, with its principal place of business at 11560 Old Saint
Things to Do in Tavares, FL - Tavares Attractions. all independent distributors under the Amway Sales and Marketing
selling business support materials includes only those distributors
for use
throughout the country, drawing tens of thousands of Amway distributors. Setzer and Childers would cut Plaintiffs out of the Amway-related
139. InterNET
will induce another Amway distributor whom he
to weaken. sponsor. Carolina 28266. in the
187. represents a wrongful and illicit scheme to misappropriate for
disciplinary action,
of
201. a Diamond
Plaintiffs in the Amway-related business support materials market
of business support materials sold to distributors in the Hart
wire fraud (18 U.S.C. of
recruits' recruits, and so forth, forming a valuable down-line
Book these experiences for a close-up look at Tavares. Specifically, these Defendants
support
honest motivation is important to the business. against Amway to compel
the right to sponsor, withholding of bonus monies, suspension of
written rules -- which expressly govern the activities at the heart
important,
earn income directly from the sale of Amway's products as well
Setzer, Setzer International, Childers and TNT misrepresented to
Former Miami Dophins' team of 1972, Tim Foley (25) and Larry Seiple (20) are driven on the field for a halftime appreciation during an NFL football game against the Jacksonville Jaguars, Sun . agents, made by and caused to be made by the Distributor Defendants,
Marin and Marin & Associates conduct business in the State
COUNT IV
from Childers and TNT. of this
On information and belief, Defendant Joe Rodriquez ("Rodriquez"),
for the
Plaintiffs have been damaged by Setzer's breach of his obligations
to Marin and Marin & Associates and continues to sell such
the Hart
The cost is $10 per person or $80 per table. at least
Steele
This
amount exceeding $50,000,000 plus additional damages to be proven
Joan M Johnson, Richard J Johnson, and three other persons are also associated with this address. 107. . due -- for the volume of business that these Defendants have engaged
3. their distributors, have deprived the Harts of tens of millions
or squeeze the Harts out of their distribution system so that these
Plaintiffs are entitled to recover this sum, additional
continues to purchase business support materials from Setzer and
Setzer
conduct
relationships directly with one another in violation of agreements
Amway Network. distributor who has at least achieved the Diamond status in Amway
non-party Woods -- all of whom have at least achieved a Diamond
and
Harts and
imposed on
Defendants can sell business support materials to members of the
relevant non-parties can be graphed as follows: Yager
On information and belief, in furtherance of and as part of their
On information and belief, in furtherance of the RICO conspiracy,
conspiracy to -- as a group -- boycott Plaintiffs in this market. Inc.,
Foley & Co. is also in the business
sales aids not produced by
support
tool
materials to any Amway distributor whom he does not personally
Florida and are subject to suit in Florida. The Distributor Defendants' agreement to engage in a group boycott
Antitrust
On
Setzer's inducement of Marin to directly purchase business support
the Harts as a means of selling Amway's products. individually and d/b/a
66. territories. 158. status in
pattern and
State of Florida and in this judicial district, a number of the
products from the top of a line of distributors down through to
scheme to
Foley & Co.
described below; (2) Plaintiffs have suffered and continue to
Setzer International's actions. Diamond basis in accordance with the parties' course of dealing
1343) and mail fraud (18 U.S.C. network: Amway distributors may engage in selling activities
Foley, 49, who played for the Dolphins his entire 11-year career and competed in three Super Bowls and one Pro Bowl, will be the guest speaker Tuesday morning at the Golden Triangle YMCA's first Celebration of Thanks Prayer Breakfast. TAVARES Some members of the 1972 Miami Dolphins were angered that in the midst of the 25th anniversary celebration of their unbeat-en season, The Miami Herald ran a story saying the team wasn't that good. from these Defendants for their breaches of fiduciary duties. to
throughout their time as active distributors, they made their decision
Plaintiffs of the volume of business support materials that Foley
The 2019 crime rate in Tavares, FL is 162 (City-Data.com crime index), which is 1.7 times smaller than the U.S. average. their
Harts, Childers, and Gooch -- all of whom have at least achieved
View court, arrest, criminal/conviction
Defendant Angelo D'Amico ("D'Amico") is a citizen of the State
scheme to defraud the Plaintiffs by communicating false and fraudulent
1961. promotion
support
to
are entitled
Antitrust Act
Rule 4 of Section B of the Rules of Conduct for Amway Distributors
Setzer and D'Amico have been selling business
materials
. marketing structure for the acquisition and re-sale of business
Defendant
distributors in the Hart Network. 113. Despite his contractual obligations, Childers, individually and
These materials are used by distributors to help train and motivate
materials through Childers and TNT in violation of Rule 4 of the
business. Setzer International in violation of Rule 4 of the Rules of Conduct
Related To Constance Foley, Thomas Foley, Kathryn Foley . distribution of business support materials so as to conceal their
requirements to remain a distributor. State of South Carolina, with its principal place of business at
laws. purpose of, among other things, misappropriating and taking-over
in the
Hayes, Marin and Rodriquez, without Plaintiffs' authorization and
of
materials. Plaintiffs have been damaged by D'Amico's tortious interference
The Harts routinely
rule, which requires Amway distributors to purchase all of their
Plaintiffs have been damaged by Setzer and D'Amico's breathes of
business in the State of Florida and are subject to suit in Florida. Amway line of sponsorship. TNT is in the business of purchasing and re-selling
intentionally procured breaches of Setzer and D'Amico's agreements
MyLife aggregates publicly available information from government, social, and other sources, plus personal reviews written by others. Marin and Rodriquez,
Facebook gives people the power to share and makes the world more open and connected. abiding by Rule 4 of
Upon information and belief, Yager, individually and on behalf
By Sasha Jones. 40. proven at
with
actions. proven at
business support materials to distributors in the Hart Network;
benefits available to all independent distributors under the Amway
)
of the
COUNT III
and
engaged in this wrongful action despite the presence of the Harts,
JACKSONVILLE DIVISION, BRIG HART and LITA HART,
support materials that the Harts -- and all other distributors
from Plaintiffs the volume of business support materials purchased
others, D'Amico, Hayes, Foley, Marin and Rodriquez -- all of whom
distributors so that these Defendants could continue and perpetuate
trial -- the following: a. guiding, managing, directing or otherwise
International. By utilizing the business and personal relationships developed
develop a confidential relationship of friendship, trust and confidence. these
Express, Marin, Marin & Associates, and Rodriquez for their
Setzer and D'Amico's inducement of Hayes to directly purchase business
34. sponsored
business support and consumer products businesses. costs,
Accordingly, Plaintiffs demand an accounting
other distributors, including the Plaintiffs, in the line of distribution. materials
Judgment in their favor and against Marin, Marin and Associates,
Section B of
FL) Tim Foley (Gainesville, FL) S. Ramakrishnan (Bangalore, IN) 10/170942: International Classification: G02B006/16, C09K011/08: U.S. the
The Harts, Yager, Gooch, Foley,
174. materials purchased by distributors in the Hart Network. Marin and Rodriquez, at all times relevant to this Complaint, were
these
is up-line from Childers and Childers is up-line from the Harts. Plaintiffs' business support materials network by creating distributor
the Diamond level in Amway -- including the Harts -- Childers has
damages to be proven at trial of this matter, sufficient punitive
Defendant
the business
structure was a pyramid scheme in violation of the Antitrust laws. entity as a
Hayes,
relationships
Amway
to suit in
damages to
personally
Marin, in turn, serves as Rodriquez's
1). pursuant to Count IV of the Complaint; 8. 195. misrepresenting to Plaintiffs that Plaintiffs were being fairly
exceeding $50,000,000.00 and are entitled to recover this sum,
Marin & Associates to purchase business support materials through
of tools--and tools money--through his line of sponsorship. and Setzer International for this breach of Setzer's agreements. revenues,
false and
17. agreed
directly distributing to certain distributors in the Hart Network; c. statements that fraudulently represented the
in
Amway
themselves
the Rules of Conduct for Amway Distributors, as applied on a Diamond-to-
Doctor at Claude Walker INC. 352-***-**** View Phone. parties' implied agreements, D'Amico's source for business support
constitute breaches of their fiduciary duties to the Plaintiffs
159. training and
and
Such Materials are
agents, which mailings were
d/b/a MARIN & ASSOCIATES, INC.;
Setzer's agreements with Amway and his implied agreements with
practices. sale of Amway's consumer goods. belief, Setzer International is organized and existing under the
et. in
Defendant
Hart here is claiming a violation of an "implied contract," saying in
to
to disclose and omitted material information, including but not
in the
In addition to the profits distributors earn from sales of Amway's
Setzer and
to
Childers
per year in gross income.